Associate Editor, Wonkhe

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Today the UK-wide standing committee for quality assessment (UKSCQA) started consulting on proposals for a new streamlined Quality Code. The new Code aims to unify the UK HE sector while accommodating the growing diversity between nations and providers. It also brings greater focus on ‘enhancement’ beyond minimum standards, and on social mobility through fairer admissions.

The current Code, with its 19 expectations of providers, underpins quality assurance across the UK HE sector. It forms part of the baseline regulatory requirements, took years to develop and is respected internationally. Its chapter-by-chapter creation, with the engagement of stakeholders, arguably produced one of the best examples of co-regulation.

However, this method of development has also led to known issues. Documents written by committee tend to be long and dense, and the current Code is no exception.

Some will have heard the (somewhat mythical) story where Madeleine Atkins of HEFCE printed the entire Quality Code and presented it to QAA in a massive Lever Arch File at the beginning of the Quality Assessment Review, showing visible evidence of its burdensome nature.

And at one point, it appeared that HEFCE planned to scrap the Code entirely, but faced strong resistance from the sector.

So a review was always coming, but both the dramatically slimmed-down structure of the proposed Code and the lack of sector involvement in its development will have surprised staff in quality offices.

Greater expectations?

Gone are the many pages of indicators, explanatory text, chapters and parts. Instead, a neat one-page table presents just four ‘top level’ expectations (two on standards and two on quality). The former is supported by four ‘core practices’, the latter by eight. These are similar to some of the previous Code’s expectations and are based on feedback from the sector, rather than started from scratch. Furthermore, it still aligns to the European Standards Guidelines (let’s not mention cyclical review).

As with TEF, the new Quality Code focuses on outcomes rather than process and with less prescription should come more freedom for providers. Some may fear this risks a tickbox exercise and doesn’t do enough to encourage enhancement, risking a more static QA system. Others may see this as a welcome change from a document with guidance that was routinely referenced as if it were law.

Time to take your supplements

Perhaps the more interesting part of this proposed Quality Code is the use of ‘supplementary practices’ for enhancement-led approaches. These are additional approaches to quality and standards, to encourage performance above the baseline. The seven examples given are student engagement, employability/entrepreneurship, work-based learning, work with partners, and flexible/distance learning.

Previously, enhancement was woven into QAA’s review methods rather than Quality Code, which often caused confusion.

These supplementary practices are a clear nod to Scotland which has fully embraced enhancement-led quality assurance, rejecting English approaches in a new quality assessment model. Appeasing all four nations will be necessary to avoid a fragmented Code across the UK HE sector, and the seven consultation questions repeatedly ask if the proposed Code serves the needs of all UK nations, as well as different providers.

UKSCQA states that the new Code has ‘students at its heart’, listing seven priority topics in the introduction which almost exactly mirror the supplementary practices. Yet, student engagement appears on this list and in the supplementary practices, rather than within the core ‘top level’ Quality Code expectations. There is one nod to student feedback within the core practice outcomes, but this is a significant downgrade for the student voice in quality assurance.

It’s unclear how the six (or more) supplementary practices will work, and others may be disappointed to note that the fundamental principles of quality assurance are missing from the core principles of the proposed Code. It’s also unclear why better use of data is listed as a priority but not an example of a supplementary practice.

A consultation hat-trick

There are effectively three consultations for the reviewed Quality Code between now and May 2019. This first one, on the table of expectations and core practices, closes on 13 December, with publication in March 2018. The second focused on structure, format, accessibility, supplementary practices, advice and guidance, and launches in April 2018 for publication in November 2018.

The third, on the long-term management of the Code, launches January 2019 before publication in May. So, plenty of consultation to get your teeth into.

Some may lament the loss of the old familiar code. But, in an evolving system that now relies on governors to have an oversight of quality assurance, it’s bound to be necessary to have shorter and more manageable documents governing the system. And whatever you think of the current quality assessment system, having experienced it for a year now gives the sector a natural opportunity to review the Code.

As QAA hope for designation from the Office for Students, so the Quality Code is brought into line with the other baseline requirements and the imminent new regulatory framework. And perhaps this direction is a sign of things to come: a Quality Code very much part of a bigger system, closer to government and with the sector less involved in developing regulation.